On March 1, 2002, Pak and Sakh were permanently enjoined by the United States District Court for the Southern District of New York from violating the securities registration and antifraud provisions of the Securities Act of 1933 and the Securities Exchange Act of 1934. The complaint in the civil injunctive action alleged that, from at least January 1998 through November 1999, while acting at the direction of Aron O. Bronstein and Tomer M. Yuzary - two other defendants who controlled Golden Lender and beneficially owned the majority of its stock - both Pak and Sakh participated in a fraudulent offering of Golden Lender stock. Pak and Sakh sold Golden Lender stock to retail customers - including many elderly and infirm customers of modest means - by means of a high pressure sales pitch that included numerous material misrepresentations and omissions.

On March 16, 2001, Pak, Sakh, Bronstein, and Yuzary were convicted of criminal charges arising out of the same conduct that gave rise to the civil injunctive action. In particular, Pak and Sakh were convicted, based on their guilty pleas, of securities fraud and conspiracy to commit securities fraud and wire fraud and sentenced to, among other things, thirty-six months and forty-one months in prison, respectively.

A hearing will be scheduled before an administrative law judge to determine whether the allegations contained in the Order are true, to provide Pak and Sakh an opportunity to dispute these allegations, and to determine what remedial sanctions, if any, are appropriate and in the public interest.